Privacy and Personal Data Protection Policy

1. How Your Personal Data May Be Processed

Pursuant to Law No. 6698 (KVKK), the personal data you share with kayaoglumakine.com may be processed by us wholly or partly by automated means, or by non-automated means provided that it forms part of a data recording system — by being obtained, recorded, stored, altered, reorganised, or in short subjected to any operation carried out on the data. Under the KVKK, any operation performed on data is regarded as “processing of personal data”.

2. Purposes and Legal Grounds for Processing Your Personal Data

The personal data you share will be processed in accordance with Law No. 6698 (KVKK) and its secondary legislation: in order to fulfil the requirements of the services we provide to our customers in line with contractual and technological requirements and to improve the products and services we offer; in order to provide information to public prosecutors, courts and relevant public officials upon request and as required by legislation in matters concerning public security and in legal disputes; in order to offer our members a wide range of opportunities or to share these within a legal framework with persons or institutions able to provide them; and in order to analyse advertising preferences.

3. Information About Third Parties or Organisations to Which Your Personal Data May Be Transferred

For the purposes set out above, the persons and organisations to which the personal data you share with kayaoglumakine.com may be transferred are: our principal shareholders, our shareholders, advertisers, our direct or indirect domestic and international affiliates; member companies using the kayaoglumakine.com infrastructure and, without limitation, persons and organisations related to the service provided; as well as programme partner organisations, domestic and international institutions and other third parties from which we receive services or with which we cooperate in order to carry out our activities and/or in the capacity of Data Processor.

Our provisions regarding cookies used for advertising purposes are set out in the “kayaoglumakine.com Cookie Policy”, which forms part of this “Privacy and Personal Data Protection Policy” that you are currently reading.

4. How Your Personal Data Is Collected

Your personal data may be processed and collected through forms on the kayaoglumakine.com website and mobile applications, in the form of information such as name, surname, address, telephone number and business or private e-mail address; preferences on pages accessed using a username and password, IP records of transactions carried out, cookie data collected by the browser, data containing browsing duration and details, and location data;

from persons who share their personal data through business cards, curricula vitae (CVs), submitting quotations and other means for purposes such as establishing a commercial relationship with kayaoglumakine.com, applying for a job or submitting an offer — obtained in a physical or virtual environment, face to face or remotely, verbally, in writing or electronically;

and additionally from data obtained indirectly through different channels: data obtained from (micro) websites and social media used for websites, blogs, competitions, surveys, games, campaigns and similar purposes, e-newsletter opening or clicking activity, data provided by publicly accessible databases, and publicly shared profiles and data from social media platforms (Facebook, Twitter, Google, Instagram, Snapchat, etc.).

5. Personal Data Obtained Before the KVKK Entered Into Force

As kayaoglumakine.com did not begin publication before 7 April 2016, the date on which the KVKK entered into force, we hold no personal data stored prior to that date.

6. Transfer of Your Personal Data

Your personal data collected by any of the methods listed above, whether processed in Türkiye or processed and stored outside Türkiye, may also be transferred to service intermediaries located abroad (to countries accredited by the Personal Data Protection Board and offering adequate protection with respect to personal data), provided that this remains within the scope of the KVKK and is in line with the purposes of the contract.

Where deemed necessary, your personal data may be transferred to our business partners with which we cooperate and/or from which we receive services for the provision and promotion of products and services; to the competent authorities that would determine your location in the event of an emergency call; to regulatory and supervisory institutions and other official bodies such as courts and enforcement offices; to other public institutions or organisations authorised to request your personal data; and to legal entities that have a commercial relationship with kayaoglumakine.com and hold your telephone number.

7. Storage and Protection of Personal Data

Pursuant to Article 12 of the KVKK, kayaoglumakine.com is obliged to prevent the unlawful processing of personal data held in its systems and databases, to prevent unauthorised access, and to take software measures such as hashing, encryption, transaction logging and access management, as well as physical security measures, in order to ensure their safekeeping. Should it become known that personal data has been obtained by others through unlawful means, the situation will be reported immediately to the Personal Data Protection Board, in writing and in accordance with the applicable legislation.

8. Keeping Personal Data Accurate and Up to Date

Pursuant to Article 4 of the KVKK, kayaoglumakine.com is obliged to keep your personal data accurate and up to date. In this context, in order for kayaoglumakine.com to fulfil its obligations arising from applicable legislation, our members are required to share accurate and current data or to update it via the website or mobile application.

9. Rights of the Data Subject Under Law No. 6698 (KVKK)

Article 11 of Law No. 6698 (KVKK) entered into force on 7 October 2016. Pursuant to that article, the rights of the Data Subject from that date onwards are as follows. By applying to kayaoglumakine.com (the data controller), the Data Subject has the right to:

• learn whether their personal data is being processed;
• request information if their personal data has been processed;
• learn the purpose of processing their personal data and whether it is used in accordance with that purpose;
• know the third parties in Türkiye or abroad to whom their personal data has been transferred;
• request the correction of their personal data if it has been processed incompletely or inaccurately;
• request the erasure or destruction of their personal data within the conditions set out in Article 7 of the KVKK;
• request that the correction, erasure or destruction of their personal data be notified to the third parties to whom the data has been transferred;
• object to a result arising to their detriment through the analysis of processed data exclusively by automated systems;
• claim compensation for damages suffered as a result of the unlawful processing of their personal data.

10. Contact and Application Method

The Data Controller Representative to be appointed by kayaoglumakine.com will be announced in the Data Controllers Registry and at the internet address where this document is published once the legal infrastructure is in place. Data Subjects may direct their questions, comments or requests to the e-mail address a.kayaoglu@kayaoglumakine.com.tr.

kayaoglumakine.com may provide its positive or negative response to the requests submitted, in writing or in a digital environment, provided that the response is reasoned and given within 30 days. As a rule, the necessary procedures relating to such requests are free of charge. However, should the procedures entail a cost, kayaoglumakine.com reserves the right to charge a fee. Such fees are determined according to the tariff set by the Personal Data Protection Board pursuant to Article 13 of the Law on the Protection of Personal Data.